This Privacy Policy (“Policy”) is executed and published by Propx App Studio, a sole proprietorship (individually and collectively, “Licensor”, “Company”, “we”, “our”, or “us”). The Policy constitutes a binding legal instrument that governs every stage of processing—as defined under applicable data-protection regimes—of any information that identifies, relates to, describes, or could reasonably be linked to a natural person (“Personal Data”) collected through the Company’s family-oriented mobile software applications (the “Applications”), distributed via Google Play. By downloading, accessing, or permitting a minor to interact with any Application, the adult user (“you” or “your”) affirmatively consents to the practices disclosed herein on behalf of yourself and any minor for whom you serve as parent or legal guardian.
Section 1 – Children’s Privacy & COPPA
1.1 Intended Audience
Our apps are created for general audiences; they are not directed to, marketed to, or intended for children under 13.
1.2 No Knowing Collection from Under-13 Users
We do not knowingly collect, request, or store any personal information from anyone we know to be under 13. If you are under 13, please do not send us your name, email, phone number, or any other personal details.
1.3 Discovery & Deletion
If we ever find that we have accidentally received personal information from a user under 13, we will promptly locate and permanently delete that information from our records.
Section 2 – Categories of Data Processed
2.1 No Account, No Sign-Up
The Applications function without user registration. We therefore do not request—or otherwise purposely acquire—name, e-mail address, telephone number, or similar identifiers.
2.2 Automatically Collected Analytics & Diagnostic Data
To maintain and improve the Applications, our authorised third-party analytics and crash-reporting tools may automatically capture and transmit the following non-identifiable telemetry:
Device make, model, and operating-system build;
Application builds number and feature usage metrics;
Imprecise geolocation limited to city-or-county level;
Crash logs, stack traces, latency readings, and other performance statistics.
2.3 Purpose Limitation
The data described in clause 2.2 is aggregated or otherwise pseudonymised and is used exclusively for debugging, performance tuning, and broad statistical insight into user behaviour.
Section 3 – External Processors
3.1 Approved Vendors
We engage the following third-party processors solely to deliver advertising, analytics, and crash-reporting functionality. Each vendor certifies, contractually or publicly, adherence to contemporary data-protection standards and COPPA-safe practices:
a) Google AdMob
Role: advertisement delivery, frequency capping, and contextual targeting limited to child-appropriate inventory.
Privacy statement: https://policies.google.com/technologies/ads
b) Google Firebase (Analytics & Crashlytics)
Role: pseudonymous usage metrics, crash diagnostics, and aggregated trend analysis.
Privacy statement: https://firebase.google.com/support/privacy
3.2 Data Segregation
The processors listed above receive only device-level, non-identifying telemetry. They do not obtain name, e-mail, precise location, or any other datum that could reasonably be linked to a particular individual.
Section 4 – Monetisation Mechanics
4.1 In-App Purchases
Certain Applications offer virtual goods or ad-free upgrades (“In-App Purchases”). The transaction is executed exclusively through the native payment pipeline of the relevant platform operator (Google Play, Apple App Store, or Amazon Appstore). We neither request nor retain credit-card numbers, billing addresses, or other payment credentials; such data is collected, tokenised, and stored solely by the platform operator under its own terms and encryption standards.
4.2 Advertising Inventory
Where In-App Purchases are not effectuated, the Application may display age-appropriate banner or full-screen advertisements supplied by the third-party ad network identified in Section 3. All ad calls are filtered through the network’s “child-directed” tag, disabling behavioural targeting, interest-based profiling, and precise location ad-requests.
Section 5 – Parental Safeguards
Before any action that could result in a charge or expose a minor to an external site—namely (i) initiating an in-app purchase or (ii) following an outbound link—our apps present a “parental gate.” This gate poses a brief age-appropriate challenge (e.g., a two-digit arithmetic or logic question) designed so that children under 13 cannot easily bypass it without adult help.
Section 6 – Purpose & Limitations on Use or Disclosure
6.1 No Sale or Rental
We do not sell, lease, trade, or otherwise monetise any data by transferring it to third-party marketers or data brokers.
6.2 Internal Uses Only
The non-personal analytics and ad-delivery data described in Sections 2 and 3 are employed exclusively to:
(a) monitor and improve app stability and performance;
(b) generate aggregate usage statistics; and
(c) serve contextual, age-appropriate advertisements.
Section 7 – European Economic Area (GDPR)
7.1 Lawful Basis & Nature of Data
We do not acquire, store, or otherwise process any information that constitutes “personal data” under Regulation (EU) 2016/679 (GDPR). Analytics and ad-serving identifiers are either disabled or pseudonymised to the point that they cannot be linked to an identified or identifiable natural person.
7.2 Processor Relationships
The vendors identified in Section 3 operate as separate data processors under Article 28 GDPR and have represented that they apply suitable technical and organisational measures to satisfy GDPR obligations. No profiling or behavioural retargeting is performed on EEA-based devices.
Section 8 - Permissions Used
8.1 POST_NOTIFICATIONS → To notify users about VPN connection status, errors, or security alerts.
8.2 FOREGROUND_SERVICE → To keep the VPN service active while running in the background.
8.3 FOREGROUND_SERVICE_SPECIAL_USE → For advanced VPN functions that require continuous secure operation in the foreground.
Section 9 – California Privacy Rights (CCPA/CPRA)
9.1 No Sale or “Sharing”
We do not sell or “share” (as those terms are defined in Cal. Civ. Code § 1798.120) personal information, because we do not collect personal information in the first instance.
9.2 Rights Nevertheless Recognised
California residents retain the right to request: (i) a description of any personal information we may have inadvertently collected, and (ii) deletion of such information. Requests may be submitted through the contact details in Section 12 and will be honoured within forty-five (45) calendar days.
Section 10 – Data Security
We employ industry-standard technical and organisational safeguards— including TLS encryption in transit, restricted access credentials, and least-privilege cloud configurations—to protect any data handled by us or our sub processors. Security controls are reviewed at least annually and upgraded whenever material new threats are identified.
Section 11 – Policy Amendments
This Policy may be modified at our sole discretion to reflect legal, regulatory, or operational changes. Revisions will be published in-app and on the Company website, and the “Last Updated” date will be adjusted accordingly. Continued use of any Application after such posting constitutes acceptance of the revised terms.
Section 12 – Contact Details
For questions, access requests, deletion demands, or any other privacy-related inquiry, please reach us at:- ( 360gamesstudio@gmail.com )